Manildra Solar Farm Best Practice Community Engagement Plan

Manildra Solar Farm Best Practice Community Engagement Plan 1.1. INTRODUCTION The Proponent has and will continue to meet and exceed both jurisdictional and voluntary best practice requirements to ensure that it maintains a good reputation and an ongoing positive relationship with the community. The Project The Proponent is developing the Manildra Solar Farm ( Manildra Solar ) close to the town of Manildra in the Cabonne Local Government Area ( LGA ). The communities within this area have an existing positive relationship with the Manildra Solar Farm. In the early stages of the development of Manildra Solar, the Proponent adopted Manildra Solar Farm s Community Engagement Policy (Section 2) to develop a Community Engagement Plan ( CEP ) specific to Manildra Solar. This sets out the key principles and goals Manildra Solar Farm has in place when engaging with its communities. During the public exhibition phase of the environmental assessment no submissions were received from the local community. 1.2. COMMUNITY ENGAGEMENT BEST PRACTICE GUIDELINES Manildra Solar Farm is committed to implementing the Community Engagement Best Practice Guidelines for the Wind Industry ( Guidelines ) released by the Clean Energy Council in 2013. The Guidelines outline a framework within which to apply the community engagement principles wind and other renewable energy projects. The framework provides a set of ideas and practices to help put into action the Guidelines central goal: to earn and maintain the renewable energy industry a social license to operate. This framework has been adapted for the Proposed Project. The framework used by the Guidelines was developed by the International Association for Public Participation (IAP2 ). The IAP2 Public Participation Spectrum ( Spectrum ) outlines different levels of engagement to suit varying degrees of impacts in the community. Where impacts are less significant, for example, the Spectrum suggests approaches such as Inform and Consult. Greater impacts on communities require approaches such as Involve, Collaborate and Empower. The objectives, activities and outcomes of implementing the Spectrum are presented in Table 5 below. Manildra Solar Farm strives for greater participation levels to produce greater community trust and ensure that decisions are not the result of developers internal processes alone but also reflect stakeholders active contributions. All points of the engagement should be based on the principles of openness, inclusiveness, responsiveness and accountability. The Spectrum is also used when developing and implementing community engagement activities related to conditions of project approval (Table 0-1). 1

Standard level Table 0-1 Public Participation Spectrum High level of engagement and community-developer relationship Community initiation Inform Consult Involve Collaborate Empower Objective Provide balanced & objective information Assist community in understanding problems, alternatives and/or solutions Obtain feedback on plans, options & decisions Work directly with the community throughout the process, from feasibility through operations & decommissioning Ensure concerns & aspirations are consistently understood & considered Partner with community in each aspect of planning, development & decision-making including the development of alternatives & the identification of the preferred solution For the community to lead the development of the project Place final decisionmaking in the hands of the community Activities & techniques Advertising and PR Website and social media Manildra Solar Farm blog Information days Open days Frequently Asked Questions Page Stakeholder briefing & meetings Information sessions & collecting feedback Feedback mechanisms Community key messages Addressing of concerns Negotiation using Fisher s core concerns framework Community funds Community committees Fundraising Local community relations Community recommended projects Outcomes Planning approval Community surveys Project champions in the community Working together on community projects 1.3. COMMUNITY ENGAGEMENT POLICY The principles of community engagement were formalised as a policy following the launch of the Guidelines. Manildra Solar Farm aims to sustain the quality of life and wellbeing of individuals and communities touched by its activities through the following Community Engagement Principles: Keeping an open dialogue with our communities. Our aim is to build strong relationships through transparent communication with communities during all aspects of development, construction and operation, whilst respecting the diverse cultures, views and needs of these communities. Manildra Solar Farm has established efficient, non-threatening, fair and accessible mechanisms for dealing with any concerns raised by the community. These are set out in the conditions of planning approval for operating assets and in the comprehensive consultation process for development projects. Fostering local relationships. Manildra Solar Farm aims to foster lasting relationships with non-profit organisations by supporting local community initiatives; however Manildra Solar Farm does not normally sponsor any partisan political activities or religious groups. Seeking to source locally. Manildra Solar Farm will seek to source materials and services from locally based suppliers to support the local economy, enhance community engagement, and to reduce its impact on the environment from transportation. Raising awareness about renewable energy. Manildra Solar Farm promotes renewable energy using factual and scientific data, and advocates for regulation that delivers increased policy predictability for the renewable energy industry. Manildra Solar Farm s parent company is a member of Australia s Clean Energy Council. Community Engagement Register: Manildra Solar Farm has developed a Community Engagement Register to monitor and track financial and other in-kind support that Manildra Solar Farm provides to local communities. 2

1.4. PURPOSE OF THE COMMUNITY ENGAGEMENT PLAN (CEP) Manildra Solar Farm is committed to community and social inclusion. It will follow the strategies of the Community Engagement Plan ( CEP ) to develop and implement a series of community consultation and stakeholder engagement activities for the Proposed Project. This will ensure broad community and stakeholder interaction through the initial site investigations, the development stage of the project, and will ensure continuing consultation during the construction and operation of Manildra Solar and deployment of ACT Storage. The purpose of the CEP is to provide the most effective tools and methodologies to: Provide information to the community and stakeholders about the development stage, why consultation is being undertaken and how the results will be used by the Proposed Project team. Provide information to the local and broader community about the Proposed Project to ensure awareness of the development process, timing, parameters and constraints so there can be informed views and input to the project team at the development stage. Demonstrate how the community can provide comment and feedback about the Proposed Project and how this will be considered by the Proposed Project team. Report the results of consultation in an easily accessible format. Manage expectations with honesty and openness. Demonstrate commitment to communities wellbeing. Become an active member of the communities, capable of creating trust and constructive relationships. Strengthen collaboration through relevant partnerships. Build community support for the Proposed Project. Assess community attitudes towards the Project at each stage, identify how attitudes and issues can be managed, and ensure the most appropriate tools and methodologies are used for further consultation and engagement activities. Assess how any stakeholder and/or community concerns and issues could affect the delivery of the Proposed Project and identify strategies to manage these. The CEP also sets out the protocols and procedures for: Developing and distributing information about the Proposed Project that is relevant and easily accessible to stakeholders, local communities, businesses, and other interested parties. Identifying stakeholders and organising project briefing sessions or meetings. Advertising community consultation activities such as public meetings and information sessions. Communicating clearly and concisely the likely impacts from construction activities in terms of noise, dust, increased traffic, timing and duration of the Proposed Project construction and implementation at all consultation activities. Ensuring all communications and consultation activities include information on how to access further information about the Proposed Project and how to contact the Project team Encouraging community and stakeholder feedback throughout the development, construction and operation stages of the Proposed Project. Taking, recording and responding promptly to all community feedback, enquiries and complaints. Reporting the outcomes of all consultation activities and stakeholder interactions Handling media and government enquiries. 1.5. COMMUNITY ENGAGEMENT PLAN OBJECTIVES The main objective of this Community Engagement Plan (CEP) is to provide overarching communications and consultations strategies, methodologies and tools to effectively inform and engage the community and stakeholders throughout the life of the Project. Achieving this objective will underpin the successful delivery of the Proposed Project. The CEP aims to: 3

Enable the Proposed Project to be an active and visible member of the community capable of creating trust and constructive relationships. Explain the strategic approach to communications and community consultation tasks at each stage of the Proposed Project. Provide a preliminary assessment of potential project stakeholders. Outline a framework for coordinating and managing stakeholder engagement and community consultation activities. Identify potential risks and opportunities. Identify and define the roles of the Proponent s community engagement team and their relationship with subcontractors, stakeholders and the community. Detail communication tools and methodologies. Clearly articulate the approval processes and timelines, and any necessary protocols for production of communications collateral and community consultation activities. Describe the controls and systems in place to ensure this plan s procedures are followed, reviewed and measured. Gather opinions and expectations about the Proposed Project and address any questions about it. Maintain communication channels for communities to raise questions and to answer them. This CEP addresses communication and consultation for both the development and construction stages of the Project. 1.5.1. Key Messages It is imperative to provide consistent key messages at each stage of the Proposed Project. Key messages are: Commitment to ongoing local community participation Commitment to the Government s Renewable Energy Target scheme to provide renewable and sustainable clean energy. Commitment to communication and consultation processes that are open, transparent and effective. Respect for local heritage, community icons, community identity and indigenous history Respect for the environment. A construction program which will be developed to minimise disruption to the community throughout construction activities. Benefits of the project to increase renewable energy level in the National Electricity Market The possibility of local employment opportunities during construction, and other positive economic benefits for rural communities. Construction activities on Manildra Solar will be planned with the aim of minimal impact on the local and wider community, with construction activities complying with the NSW Department of Planning and Infrastructure s Planning Approval Conditions of Consent. The Proposed Project team are available to respond to public s concerns 24x7. All community feedback is respected. The community will be notified about the Proposed Project s progress and construction impacts. Project contact details will be listed on all communication material and placed on the Proposed Project webpage on the Manildra Solar Farm website, and Manildra Solar Farm s social media channels. 1.6. HOW MANILDRA SOLAR FARM ACTIVELY PARTICPATES IN THE COMMUNITY Manildra Solar Farm works diligently to maintain its good reputation and a positive relationship within the community. A budget of $4,000 is allocated for community initiatives each year and $3,000 of this budget goes directly to local sponsorships. This budget will be increased when the project moves into construction an operation phases. Manildra Solar Farm has budgeted $10,000 per year for community initiatives in Manildra during operation. 4

1.6.1. Community Consultation and Feedback It is important for Manildra Solar Farm to engage with and support the communities in which it operates. Engagement with the community during development, construction and operation is an ongoing priority for Manildra Solar Farm employees. Feedback mechanisms include face-to-face interaction at community events, Manildra Solar Farm s website, the project specific complaint email, a 24x7 dedicated complaints line set up at (02) 9002 7733. Any concerns raised via feedback mechanisms or made directly to the project or site managers, are assessed and reported to Manildra Solar Farm's Asset Manager. Manildra Solar Farm has been involved with the local community during the planning and development stages of the project, and this will continue through the life of the solar farm. At the early stages of development Manildra Solar Farm hosted community meetings and invited members of the public to attend to learn about and ask in relation to the proposed development. Manildra Solar Farm staff and third party experts are present to provide information to the community. A community information day was held for the Manildra Solar project on 3 August 2010 at Manildra Memorial Hall during public exhibition of the Environmental Assessment for Development Approval. The register from the day records positive and supportive responses from 20 community member attendees. Following this information day, a number of local business contacted Manildra Solar Farm to offer services such as accommodation and earthworks. Following the completion of the consultation and exhibition of the Environmental Assessment (EA), no community submissions were received. This demonstrates the strong support and acceptance of the project from the local community. Open community meeting are held on an ongoing basis. The most recent meeting was held on 5 th August 2015 to inform the community about the project s recent modification in tracking technology, answer general project questions and consult with and involve community in planning of upcoming community activities, including Raising awareness of renewable energy through school outreach programs and sponsorship opportunities. Manildra Solar Farm also launched its new Manildra Solar community website as an additional medium for information, consultation and feedback. At the commencement of operation of Manildra Solar, Manildra Solar Farm will support the formation of a Cabonne Community Fund Committee ( CCFC ) made up of community members to administer a $10,000 community fund. Applications for funding will be considered from organisations that: Deliver social or environmental projects or services to residents in the community Have a proven track record of achievement and sound project management, or are otherwise able to show the capacity to achieve their stated aims and objectives Have similar objectives as the CCC that are in line with socially and environmentally responsible practices 1.6.2. Communications and Media Manildra Solar Farm communicates and invites feedback through a variety of mediums. Project details are regularly updated on Manildra Solar Farm s website, and the page includes videos, links to photos, project documents, fact sheets, media releases and newsletters. Each quarter during operation, Manildra Solar Farm Energy issue will issue community updates in the form of newsletters that are posted on the website and emailed to regional newspapers. The purpose of the newsletter is to inform the community of any changes that have been made at our operating assets and includes general information and project updates.. Fact sheets provide consistency of information released to the public and will continue to be developed for the Project as it progresses and construction milestones are achieved. Fact sheets will be prepared on issues expected to be of wide interest, and may include stages of construction, construction methods, noise impacts, safety, environmental safeguards, sustainability initiatives, traffic impacts, and compliance with Conditions of Approval. 1.6.3. Manildra Solar Community Website In July 2015, Manildra Solar Farm launched new Manildra Solar community website as an additional medium for information, consultation and feedback. This website will be a portal of information about Manildra Solar and renewable energy in Australia, provide case studies demonstrating benefits and 5

opportunities for community stakeholders in renewable energy projects. It will also be a medium of two way dialogue for community groups and members to provide suggestions and feedback to the project and apply for sponsorship and in-kind support for community initiatives. Manildra Solar Farm will gather feedback from the community on how community members would like to use this website and adjust it accordingly. This is a new initiative Manildra Solar Farm is launching to inform, engage and empower the Manildra community to be part of the solar farm development. 1.6.4. Community Partnerships NSW Regional Clean Energy Program Manildra Solar Farm has been working with the Regional Clean Energy Program ( RCEP ) of the NSW OEH, and the South East Regional Coordinators to create opportunities for communities throughout NSW to fully participate in local renewable energy initiatives. Manildra Solar Farm and RCEP have worked together to present and develop the following community events: Promotion of renewable energy through facilitating community open days Raising awareness and building relations though regular coordinated site visits Engineers Without Borders Australia In 2015, Manildra Solar Farm is partnering with Engineers Without Borders Australia and schools in Cabonne LGA to develop and run High School Outreach ( HSO ) modules within the Cabonne region. The HSO modules with focus on renewable energy technology and the role it plays in Australia s electricity mix. The modules will link back to the Manildra Solar development and other energy infrastructure in the community and highlight career paths to renewable energy engineering. Students and teachers will have the opportunity to talk with university students and Manildra Solar Farm staff throughout the program. The result of this initiative is that community members will have greater understanding of the project and the benefits it brings including employment and community input opportunities. 1.7. STAKEHOLDER ANALYSIS AND ENGAGEMENT 1.7.1. Stakeholder Communication Strategy The stakeholder communication strategy engaging with stakeholders is to outlined in Table 0-2. Table 0-2 Communication strategy Inform Consult Collaborate Stakeholders who are not directly affected, but require factual and transparent information to help them understand any problems, alternatives, opportunities and solutions (e.g. via advertising, newsletters, website). Stakeholders who may be directly affected or have a greater influence on, or are impacted by, project outcomes. We will consult with them to understand their concerns, and where appropriate, consider their input and feedback in planning, analysis, options development and decisions (e.g. via project briefings, submissions, surveys, meetings). Stakeholders where approval may be required or who hold ultimate responsibility for a decision (e.g. design and construction approvals, permits, legislation). We will identify and engage with these stakeholders early to understand and address any key issues, to maximise mutual opportunities and provide stakeholders with all information to enable them to provide timely approvals (e.g. via briefings, workshops, interface meetings, compliance reporting). The following listed stakeholders have been identified as having an interest in the Proposed Project and will be consulted as required. The Proponent will continue to expand the list of stakeholders throughout the life of the project and update and maintain the information on a database, along with any issues or queries that are raised. The stakeholders and issues included in the database will then provide a key 6

communications tool for the Proposed Project and assist with identification of issues trends and subsequent management strategies. 7

Federal, State and Local Government Table 0-3 Project Stakeholders Of The Proposed Project Stakeholder Concern or Interest Management Strategy Federal and State Member Access to information Community concerns Local Councils Access to information Community concerns and interest Government Agencies Impacts to council assets Consultation during development process Effect on local employment and business Construction status NSW Office of Environment and Heritage Access to information Pollution control including noise, water, air, land and waste NSW Department of Planning and Environment Access to information Construction impacts Operational impacts Community impacts and disruption Consultation during the development process Consultation during the development process Community access to information NSW Office of Communities - Aboriginal Affairs Access to information Heritage Employment opportunities NSW Department Primary Industries Access to information Pasture protection Construction impacts Consultation during the development process Operational impacts Weed/noxious plant control Pest control Initial project briefing as required Project updates Project website and social media Open days Initial project briefing as required Project updates Project website and social media Open days Environmental Management Plan Heritage Management Plan Project updates Enquiries and Complaints Management Infoline contact Project website Project briefing/meeting Environmental Management Plan Infoline contact Project email Project website Environmental Management Plan Infoline contact Project email Project website Environmental Management Plan Infoline contact Project email Project website 8

Stakeholder Concern or Interest Management Strategy NSW Trade and Investment Access to information Employment opportunities NSW Environmental Protection Authority Access to information Construction impacts Traffic and Transport Local Councils Roads and Maritime Services Emergency Services Police Ambulance Rural Fire Services State Emergency Services Bungendore unit Local, Community and Interest Groups Landowners/tenants adjacent to Manildra Solar Landowners of ACT Storage Operational impacts (particularly noise) Consultation during the development process Community access to information Access to information Community concerns and interest Impacts to council assets Consultation during development process Project awareness Construction status Delivery timings Access to information Road and traffic impacts Changes to property access Construction status Access to information Impacts on property values Damage to boundary fencing, stock grids, gates Damage to trees/shrubbery Noise/pollution during construction Infoline contact Project email Project website Project briefing/meeting Environmental Management Plan Infoline contact Project email Project website Environmental Management Plan Initial project briefing as required Project updates Project website and social media Open days Project briefings and ongoing consultation Traffic management plans Delivery and/or construction hours/activities Project and construction updates Infoline contact Project website and social media Personal consultation Project and construction updates (notifications) Information sessions and feedback forms Enquiry and complaints management Infoline contact Project email Project website and social media Newsletters 9

Stakeholder Concern or Interest Management Strategy Local communities Access to information Employment opportunities Interest groups Agricultural associations Agricultural show societies Progress/business associations Tourism associations (e.g. Capital Region Living) Aboriginal Land Councils Local heritage groups and historical societies Agricultural field days (e.g. Australian National Field Days Assoc.) Shires association Economic benefits Local business support Local resource provision Innovation Community/regional benefits Impacts/risk to historical icons Asset protection Access to information Environmental impacts Local area promotion Benefits local businesses Schools and kindergartens Education opportunities about renewable energy Project participation activities Project updates (notifications) Advertising and media releases Information sessions and feedback forms Enquiry and complaints management Infoline contact Project email Project website and social media Open days Community events Newsletters Sponsorships Briefings/meetings (as required) Project updates (notifications) Advertising and media releases Infoline contact Enquiry and complaints management Project email Project website and social media Post construction information sessions at schools Enquiry and complaints management Infoline number Project email Project website and social media Design and painting activity for the Project promotion (optional) Education program Open days 10

Media WIN TV Corporation Prime Television Local and regional newspapers The Land Community Radio ABC TV and radio Stakeholder Concern or Interest Management Strategy Community benefits Road and traffic impacts Environmental impacts Construction impacts Employment opportunities Tourism promotion Access to information Media releases Project a updates (notifications) Infoline contact Enquiry and complaints management Project website and social media Project email 11

1.8. ENVIRONMENTAL ASSESSMENT STAGE The following community consultation process was undertaken during the Manildra Solar environmental assessment stage. The public consultation for Manildra Solar commenced with the submission of the Preliminary Environmental Assessment to the NSW Department of Planning and Infrastructure ( DoPI ) (now NSW Department of Planning and Environment ( DPE ) in July 2010. Manildra Solar Farm has a policy to directly notify all existing landowners residing within a 3km radius around the project area; to inform the immediate community of the Proposed Project and stage of the project development; to give them opportunity to go over any questions or concerns; and to inform them of the planned community information day. Community consultation for Manildra Solar during the development phase was completed through the following means: An information day hosted by the Proponent on 3 August 2010 at the Manildra Memorial Hall Telephone discussions with the public and various government authorities Presenting a digital presentation outlining the background and experience of the Proponent and scope of the project Follow up emails with project specific details including additional requested information One-on-one meetings with the public and government authorities Ongoing consultation meetings with various stakeholders throughout the project planning and life cycle Following the submission of the draft Environmental Assessment, the EA was formally exhibited by the DoPI between 11 November 2010 and 13 December 2010. During the exhibition period, submissions were invited from relevant agencies and members of the public. No submissions were received from the community and four submissions were received from government agencies on the exhibited EA. A Submissions Report was prepared by Manildra Solar Farm and made public. Project approval was subsequently granted by the Planning Assessment Commission of New South Wales on 3 March 2011. 1.9. PLANNING APPROVAL AND CONDITIONS OF CONSENT In March 2011 the project approval and conditions for consent were received for Manildra Solar. Part C of those conditions (prior to construction) includes conditions for community and agency consultation, including Office of Environment and Heritage Cabonne Council Roads and Traffic Authority Local community and general public NSW Office of Water These conditions include making documentation available for public inspection on request, setting up and maintaining a project information website, preparing and implementing a community information plan and ensuring a complaints management procedure is in place. This will be implemented in parallel with Engineering, Procurement and Construction Contract negotiations. 1.10. MANILDRA SOLAR CONSTRUCTION STAGE Community consultation and stakeholder engagement will continue during the construction, deployment and operation stages of the Project, with activities and events scheduled to align with project milestones. 12

1.10.1. Project Construction Community Consultation Community consultation and stakeholder engagement will continue during the construction stage of the Project, with activities and events scheduled to align with project milestones. These may include a sod turning ceremony, installation of the first/last solar Panel, commissioning or other notable stages of construction. During the construction stage of the project, the Proponent will ensure the activities detailed in this plan are implemented. It will be essential to continue to provide information to the communities throughout construction; and establish relationships and mechanisms for stakeholder engagement that will continue to be used throughout the remaining operational lifetime of the Project. 1.10.2. Communications Coordinator The Communications Coordinator will: Be responsible for providing strategic planning and management of stakeholder briefings/meetings Liaise with the construction site manager and other relevant project personnel Lead stakeholder briefings/meetings and community consultation activities Develop media releases and media kits, as required Participate in community and public meetings or forums, including business functions or community interest group meetings Field and respond to project specific stakeholder or community enquiries and complaints Ensure feedback, enquiry and complaints management strategies and processes are rigorously adhered to 1.10.3. Construction communication and consultation tools During the construction stage of the Project, community consultation will focus more on engaging the community, providing information about key construction activities, handling enquiries and complaints, encouraging project championing and celebrating project milestones. Please refer to 1.11 following, for information on communication and consultation tools. 1.10.4. Community Consultation Activities During Construction The following activities will be undertaken during the construction phase of the project At notice that project will proceed to construction Strategic media placement e.g. local media. Share local employment opportunities through the ICN and other local employment agencies. Prior to start of Construction Direct contact by Contractor informing Manildra residents of community website, construction activities, construction traffic routes and any potential disruptions to traffic flows and amenity impacts and setting out project timeline and details of Community Information Day. Community Information Day with representatives from Manildra Solar Farm Pty Ltd and the appointed construction contractor available to answer questions and explain project details. This Information Day will provide details of Construction activities e.g. construction timeline, staging of construction activities, expected milestones During Construction Construction Traffic routes e.g. maps with routes highlighted Details of how to provide feedback or make complaints Layout and general arrangement of solar farm 13

Periodic updates of the community website and social and/or traditional media explaining contruction progress and any key activities completed or about to commence e.g. delivery of equipment, first generation etc Direct correspondence with local community in the event of any construction work that has been approved by DPE outside of specified construction hours (if applicable) Public and stakeholder-specific meetings o o o Meeting with individual community members or groups as requested if appropriate Information Days, presentation days and meetings as appropriate The typical agenda for these meetings will be include: Introduction to project and participants Update on project status, timeline to completion and explanation of next month of construction activities Summary of any complaints and feedback and resulting actions taken by Manildra Solar or contractor, if appropriate Meeting/stakeholder-specific topics Opportunity for questions or discussion Details of how to provide feedback or make complaints Close If catered, best endeavours will be taken to use local catering services. Attendees will be required to sign into the meeting, minutes wil be taken (including any questions and answers and any follow up to be taken). Minutes will be published on the Manildra Solar Farm website and distributed to attendees upon request if appropriate. Attendees will be added to the Community Enagement Register. Participate in community events Maintain Complaints Register and comply with Complaints procedure At End of Construction Transition to operation stage activities refer to section 1.15 for ongoing engagement framework. Community will be informed of Community Information Day and any public meetings or presentations through the Manildra website and through an advertisement in a newspaper circulating in the area e.g. Manildra Matters, Central West Daily or Molong Express (chosen based on appropriateness of distribution timing). 1.10.5. ARENA Reporting Requirements Manildra Solar will provide regular reports to ARENA, including a summary of community engagement activities undertaken in accordance with its obligations under the ARENA funding agreement. As part of this reporting, Manildra Solar will provide to ARENA notification of all submissions, complaints and questions arising from community consultation and responses provided to any submissions, complaints or questions arising from the community consultation.. 1.11. COMMUNICATIONS, RISKS AND OPPORTUNITIES Manildra Solar Farm s Communication Process involves identification of risks/ opportunities, risk assessment and implementation of mitigation strategies. The process is linked to all other activities and reporting requirements of the Project. The communications risk analysis process covers five basic steps which are required to ensure that an effective approach is adopted to manage relevant risks. These basic steps are: Planning including clear information about scope, the Proponent s organisation, context of the Project and communications procedures. 14

Identification of risks and opportunities. Assessment and analysis of those risks and opportunities, both qualitatively and quantitatively. Management including assignment of responsibility, timing and response to communications issues. Review and reporting of the results, including analysis of performance and communication of those results. 15

THE PROPOSED PROJECT RISKS AND OPPORTUNITIES Table 0-4 provides an initial list of the possible issues and risks and the Proponent s strategies to manage each issue. The table also highlights potential communications opportunities. Environmental Incident Table 0-4 Risk and Opportunity Matrix Issue Who is affected? Risks and opportunities Management strategy The Proponent Project delivery team Local environment Local residents Risks: Soil contamination Weather Geotechnical discovery Opportunities: Incident free delivery Improved reputation Environmental Management Plan Incident communication protocols Poor workforce behaviour The Proponent Project delivery team Local community Risks: Complaints from local community Damage to public and private roads Negative media coverage Lack of community support for project Project delays Opportunities: Adherence by all team members and subcontractors to Proponent s code of conduct to minimise incidents and complaints Community as project champion Staff inductions/tool box talks Infoline cards to give to anyone asking questions or complaining direct to project team members or site personnel All interaction with community and media to be led by Communications Coordinator Monitoring social media and addressing relevant issues raised Graffiti and/or vandalism The Proponent Project delivery team Local Community Risks: Increased project costs Negative local media coverage Damage to property Opportunities: Community champions the project and supports watching over the Project site for suspicious or untoward activity Construction Management Plan Site security 16

Issue Who is affected? Risks and opportunities Management strategy Aboriginal Cultural Heritage The Proponent Local indigenous groups Aboriginal Land Council Department of Communities- Aboriginal Affairs Local community Community safety The Proponent Community Site visitors Site workers WorkCover Risks: Issues with Council and/or Heritage Groups and/or Land Council Opportunities: Involve local school students in heritage identification/protection plan Risks: Injury to member of public or visitor Property damage Negative media coverage Opportunities: Involve local school primary students in project safety campaign Site induction includes awareness of procedures if possible Aboriginal objects or relics are uncovered Site areas kept secure Safe Work Method Statement for all works Safety Management Plan Safety signage Appropriate site security Community information campaign about safety when visiting the site and about site security Inductions for staff, subcontractors and site visitors Appropriate PPE for construction team and site visitors Lack of community support for the project The Proponent Project delivery team Risks: Complaints Issues raised with local MP Delays to project Negative media Protests Opportunities: Creating a local Project presence in the local community before major construction works begins Clear messages about Project benefits to the local and wider community Personal consultation with adjacent landowners/residents/tenants Early consultation with stakeholders Hosting open days Swift and effective response to complaints and enquiries Update key stakeholders and local media throughout the life of the project 17

1.12. COMMUNICATIONS MANAGEMENT SYSTEM A comprehensive comprehensive database is used to to record, monitor and report on all interactions with all stakeholders, community and other interested parties. The elements of this system will include: Information phone number (Infoline) Email and Website Social media Project contact database 1.12.1. Project Infoline, Email and Website A dedicated project information number (Infoline) is established to provide a central point for taking all enquiries and complaints for the Project. The Infoline phone number will be will be included on the project website, all notifications, advertising and signage and any other information in the public domain relating to the Project. All calls regarding the Proposed Project dedicated Infoline will be directed to a Project team member or Site Manager, who will answer and determine whether the call is an enquiry or complaint. In the case of complaints, the team member will determine which of the Project contractors should be contacted to investigate the matter, or whether it needs to be forwarded to the Communications Coordinator. All enquiry calls to the Infoline or email require a verbal response within 48 hours during times when construction is being undertaken or the next working day (unless the contact agrees otherwise). All calls, both enquiries and complaints, are logged, tracked and closed out on project contact database. 1.12.2. Project Contact Database A contact database will be used as the main reporting and monitoring tool for project communications activities. In addition to managing interaction with the community and key stakeholders, the system will be utilised to record progress of interactions with any other parties. Record all community and stakeholders contacts and interaction. Record the issue and distribution of letterbox drops, project updates and notifications. Be the management tool for recording all complaints, enquiries, issues and responses. Provide monthly reports on stakeholder and community contact and issues management. Be utilised to identify issue and opportunity trends through key word referencing. 1.12.3. Stakeholder Database A database will be established to manage all stakeholder information including contact details and area of concerns or interest. The database will be maintained by the community relations team over the life of the project, but only be used to facilitate ease of contact with stakeholders. The information in the database will not be provided to any other person or agency. 1.12.4. Complaints Handling and Reporting The procedure for complaints handling is as follows: All complaints received during business hours will be investigated and responded to within 48 hours of receipt where practical. Complaints received overnight or on weekends will be responded to within 48 hours unless otherwise agreed with the complainant, but no later than the following business day. Written correspondence regarding the Project will be answered within seven working days of receipt. Experience has revealed that some complainants merely want to voice their concerns immediately and be listened to, and once they have lodged their complaint, they prefer to be called back in business hours, if at all. A detailed written response will be provided to any complainant who gives their details, within fourteen calendar days to close out the complaint. 18

It is possible that false or negative statements associated with the Project are made on social media channels. Social media channels will be monitored for such statements. If detected, Manildra Solar Farm s Communication Manager will consider the strategy of response to either direct the complainant to publically available correct information or gather more information to address the complaint. 1.12.5. Complaint Escalation and Dispute Resolution When a complaint is received, there will be occasions where a satisfactory resolution cannot be immediately agreed with the complainant. Should this be the case, Manildra Solar Farm will follow an internal complaints escalation process and will seek further dialogue with the complainant to negotiate a successful outcome and resolve the complaint. If the complaint is still not able to be resolved to the satisfaction of the complainant, a staged dispute resolution process will be implemented and the complainant will be able to request intervention and mediation by an Independent Community Liaison Representative. 1.12.6. Media and Government Relations Media enquiries are defined as enquiries from journalists and other personnel with the intention of creating mass communications (principally newspapers, radio, television and blogs) to distribute to the public. Enquiries may be received via the Infoline, face-to-face contact, email, letter, fax or meeting. Media enquiries will be managed by Manildra Solar Farm s communication unit. Manildra Solar Farm s communication unit will be immediately informed of any media or Government request received by site personnel or any subcontractor. Only the communications unit will provide a statement (written or verbal), photographs or illustrations to the media or elected officials, unless there is formal delegation of this function to another area within the project team. The following protocols will be observed when any member of the project team is approached with a media or government enquiry: Always be polite and courteous. Do not attempt to answer the enquiry. Indicate that you are not authorised to speak to the media, obtain details of the enquiry and advise that the Project Communications Director or representative will respond to the enquiry. Do not engage in any off the record conversations. Refer the enquiry to the site supervisor who will pass the enquiry to Manildra Solar Farm Energy s communication unit. These protocols will be included in the induction process to ensure all Project team members and subcontractors comply with the protocols so as to respond appropriately to any media or government enquiry. 1.13. INTERNAL COMMUNICATIONS Internal communications across all members of the Project team will be vital to the success of this project. Communications will be managed through the Communications Coordinator. Internal communications activities aim to create an organisational culture across all the organisations working on the Project, whether directly employed or employed as subcontractors, and reinforce principles of: Employee engagement and outcomes focus. A culture of performance on the outcomes of both what we do, and how we do it. A shared set of values is the core of successful project outcomes and communication across all disciplines of the project team, the community and stakeholders. Included in the values will be those of safety, respect, honesty, focus and recognition. Manildra Solar Farm considers behaviour deliverables as equally important to other deliverables of the Project. Performance of the construction team will be measured, not just by what the team delivers, but how they do it. All team members and subcontractors involved in the Project will be encouraged to exhibit positive, supportive and tolerant behaviour and play a role in the project goal of being a good neighbour to the local communities. 19

1.13.1. Communications Materials Approval All written materials will be submitted to the Communications Manager for approval, prior to printing and distribution. This includes advertising, notifications, posters, fact sheets, briefing notes, presentations, letters and web updates. 1.13.2. Site Inductions The site induction process for all permanent and temporary staff and subcontractors of the Proposed Project includes a safety induction. The safety inductions form the basis of the Project s code of conduct and the Proponent s commitment to positively engaging with and minimising disruption to the community, property owners, businesses and all transport and road users. This commitment underpins instructions and messages to all new staff during their mandatory Project safety inductions. As part of the induction process, all employees and subcontractors will be made aware of the requirements under the code of conduct and the CEP. This includes a commitment to keeping the community informed by delivering timely, clear and concise information about the Project. At the commencement of each shift, a tool box talk will be conducted by the site manager with construction personnel and any relevant subcontractors. Tool box talks will reinforce safety procedures and the Proponent s code of conduct and advise the site crew and subcontractors of exceptional circumstances that may be encountered during that shift. 1.14. ISSUES AND INCIDENT MANAGEMENT The Project will undoubtedly attract a degree of public interest, some positive and some negative, and/or stakeholder dissatisfaction about the project, the construction, disruptions to amenity, traffic and business and long term implications for the local and regional areas. Key issue management principles include: Reviewing all issues for their status major, intermediate or minor based on the risk to the Project (and therefore, the Proponent). Ensure the local community and relevant stakeholders are informed of the progress of construction and advised of any actions to pre-empt or respond to issues. Evaluating community enquiry/complaint outputs from the contact database on a regular basis to identify any emerging issue trends. Evaluating participation and feedback from information session feedback forms to gauge community interest and identify constant or emerging or issue trends. Timely response to all issues, both internal and external. 1.14.1. Incident Management Managing and reporting incidents is critical to the successful delivery of the Project. Process controls will be in place to ensure stakeholder issues or incidents that can attract media attention; threaten the Project or Proponent; disrupt the community; and result from natural events or criminal incidents; are effectively managed. Judgment will be exercised by Manildra Solar Farm s communications unit in consultation with the Project team regarding the category level of the incident, to determine whether it is minor, intermediate, or major. Major incidents are capable of affecting the daily management of the Project or damaging the reputation of the Proponent, even in the short-term. All incidents will be reported within the timeframe identified in the table below. 20

Degree of Incident Minor Intermediate Major Description Any minor issue/incident that may at some point attract the attention of the media, any MP, local council or the broader community including but not limited to industrial, community impact, legal, and commercial issues. Any issue / incident that is likely in the short-term to attract the attention of the media, any MP, local council or the broader community including but not limited to environmental, industrial, community impact, legal, and commercial issues. Any issue/incident that that has attracted or will imminently attract the attention of the media, any MP, local council or the broader community including but not limited to environmental, industrial, community impact, legal, and commercial issues. Action required Verbal notification to the within 24 hours. Same-day (24h) verbal notification. Note: for environmental, one hour verbal notification required. Report detailing the incident to be issued within 24 hours of incident, wherever practical. Immediate verbal notification from the construction manager within 10 minutes (wherever practical) to the Proponent s Asset Manager and Communications Manager. Report detailing the incident to be issued within four hours, wherever practical. Table I5 Incident management reporting 1.15. MONITORING, EVAULATION AND REPORTING Monitoring, evaluation and reporting on the effectiveness of the communications activities for the project will be undertaken: Daily via - complaints and enquiry recording in contact database - occurrence reporting (incident reporting) - media monitoring Monthly via - project internal monthly report - KPI audits and performance reviews Quarterly via - develop CEP scope of works for the next 3 months 6 monthly via - CEP document review As required via - Project internal peer audits - community and stakeholder feedback - Minutes of meetings. As required, reports on communications and consultation activities will be provided to other key groups (government or non-government) nominated by the Commonwealth to ensure improvement of community engagement. 1.15.1. Community Consultation Evaluation Evaluation enables continuing improvements to our community consultation activities. It also enables more efficient use of resources through screening or improving activities less successful or popular with communities. The communication unit will evaluate individual activities, as well as the whole program of consultation and engagement, throughout the life of the project. Each community consultation activity is evaluated as soon as it occurs and the results used to modify the overall CEP if necessary. The plan is also evaluated at key stages/milestones of the Project to see if objectives and strategies are still relevant, and at the end of the project to determine its success. 1.15.2. Effective Community Liaison Activities Measuring the effectiveness of community consultation activities will be against the Proponent s desired outcomes of: 21